Zeichner v. Mamaroneck Union Free School District

25 Misc. 3d 339
CourtNew York Supreme Court
DecidedJune 24, 2009
StatusPublished

This text of 25 Misc. 3d 339 (Zeichner v. Mamaroneck Union Free School District) is published on Counsel Stack Legal Research, covering New York Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Zeichner v. Mamaroneck Union Free School District, 25 Misc. 3d 339 (N.Y. Super. Ct. 2009).

Opinion

[340]*340OPINION OF THE COURT

Mary H. Smith, J.

It is ordered that this motion by respondent Mamaroneck Union Free School District for summary judgment dismissing this proceeding is hereby disposed of as follows:

Initially, the court notes that an attorney who is a party to a proceeding does not enjoy the privilege of using an affirmation. (See CPLR 2106; Seven Acre Wood St. Assoc. v Town of Bedford, 302 AD2d 511 [2d Dept 2003]; see also Slavenburg Corp. v Opus Apparel, 53 NY2d 799, 801 n [1981]; Matter of Flaton v Caso, 86 Misc 2d 695, 698 [Sup Ct, Nassau County 1976].) Pro se petitioner’s opposition is thus in improper form. Nevertheless, in the absence of an objection thereto by respondent, same has been read and considered.

Petitioner had commenced this CPLR article 78 proceeding seeking relief granting a permanent injunction enjoining respondent District from proceeding with educational, psychological and social testing of plaintiff’s minor son, Zachary, who recently has completed third grade, for alleged learning disabilities, which testing request had been initiated by the infant’s mother, Nadege Crespin.1 Zachary’s parents unfortunately remain in disagreement on the issue of Zachary being evaluated by the District and of critical importance is the fact that neither parent heretofore has been given exclusive decision-making authority regarding Zachary’s education.

Presently, respondent District is moving for summary judgment dismissing this proceeding as a matter of law based upon alleged lack of subject matter jurisdiction due to petitioner’s failure to have exhausted administrative remedies and based upon a failure to state a cause of action. According to respondent, since administrative review procedures are available under the Individuals with Disabilities Education Act (IDEÁ), which statute identifies, locates and evaluates all children with disabilities residing within a school district’s boundaries (see 20 USC § 1400 et seq.), and petitioner has not properly pursued such remedies, this court lacks subject matter jurisdiction to entertain this proceeding. This court disagrees in this instance and, accordingly, the District’s dispositive motion is denied.

[341]*341As this court understands the matter before it, petitioner father had made clear in written correspondence to respondent District, dated on or about November 28, 2008, that he was adamantly opposed to Zachary undergoing testing regarding his possible need for special education services. This court is mindful that it had been Zachary’s mother — not Zachary’s teacher or the District — who had initiated the request for testing.2 Consequently, the District was placed in the untenable situation of being statutorily required, pursuant to Zachary’s mother’s request, to pursue appropriate evaluation of him,3 while at the same time being refused permission to so proceed by Zachary’s father.

It appears from the record at bar that petitioner had been apprized of Ms. Crespin’s request that Zachary be tested and that he thereupon had received from the District a copy of the procedural safeguards notice and a copy of the parent guide to special education. While neither of these documents has been included in the record at bar, respondent’s counsel states in respondent’s memorandum of law that these documents included notice to petitioner regarding his right to request an impartial due process hearing. Having failed to do so, it is [342]*342respondent’s argument that petitioner is now precluded from bringing this proceeding.

There exists both a federal and a state statutory scheme which generally require that all school age children receive appropriate public education to meet their specific learning needs. Respondent, for the most part, has referred to the federal statute in making its argument and it is not apparent to what extent the two schemes overlap.

While it previously has been held that actions brought under the IDEA generally must adhere to the exhaustion requirement4 (see e.g. Heldman on Behalf of T.H. v Sobol, 962 F2d 148, 158 [2d Cir 1992]; Hope v Cortines, 872 F Supp 14 [ED NY 1995], affd 69 F3d 687 [2d Cir 1995]), those cases universally appear to involve review of the determinations as to whether a child’s disability has been properly identified, the type of educational resources to be made available and the individual education plan (IEP) that properly should be implemented. Indeed, recently, our Court of Appeals has held that “[a] ‘parent’ who is dissatisfied with an IEP ‘may file a complaint with the state or local educational agency,’ to be resolved through a due process hearing.” (Fuentes v Board of Educ. of City of N.Y., 12 NY3d 309, 313 [2009].) This line of cases, however, is wholly separate and apart from the issue presented at bar. While respondent argues that this proceeding must be dismissed because petitioner has failed to pursue his administrative remedies, a careful reading of respondent’s submissions makes clear that respondent has failed to specifically identify what is the administrative review process under IDEA that petitioner had been required to pursue to prevent his son’s testing in the first instance. Indeed, respondent states, without referencing any statutory authority, that “administrative procedures are available to review petitioner’s challenge of the CSE’s intent to evaluate Zachary for the possible presence of an educational disability” (mem of [343]*343law at 7), but then it references only statutes and regulations which afford certain procedural safeguards during and after the evaluation process.

As this court reads the IDEA, upon petitioner’s objection to his son being tested, it had been incumbent upon respondent District, not petitioner, to have initiated proceedings before an impartial hearing officer to determine whether an evaluation of Zachary over petitioner’s objection nevertheless should take place. (See 20 USC § 1414 [a] [1] [D] [ii] [I]; Durkee v Livonia Cent. School Dist., 487 F Supp 2d 313, 316 [WD NY 2007].) The District, however, never pursued this, and it fails herein to address this statutory requirement and specifically its failure to have done so. It would be fundamentally improper for this court to agree with respondent that this proceeding must be dismissed based upon petitioner’s failure to have pursued and exhausted his administrative remedies under the IDEA when petitioner not only had not been properly apprized of available review remedies under the IDEA with respect to his objection to Zachary being evaluated and tested, but respondent clearly did not fulfill its statutory duty and had failed in the first instance to properly initiate having the issue of petitioner’s objection to the testing addressed by a hearing officer.

Nor does respondent’s motion fare any better under a state statutory analysis. The Education Law has implementing regulations which state that either a “parent or school district may file a due process complaint with respect to any matter relating to the identification, evaluation or educational placement of a student with a disability, or a student suspected of having a disability, or the provision of a free appropriate public education to such student.” (8 NYCRR 200.5 [i] [1].) The Education Law also sets forth an appeal procedure where “the parent . . . of a student. . .

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Related

Hope v. Cortines
69 F.3d 687 (Second Circuit, 1995)
Hope v. Cortines
872 F. Supp. 14 (E.D. New York, 1995)
Durkee v. Livonia Central School District
487 F. Supp. 2d 313 (W.D. New York, 2007)
Fuentes v. Board of Education
907 N.E.2d 696 (New York Court of Appeals, 2009)
Weiss v. Weiss
418 N.E.2d 377 (New York Court of Appeals, 1981)
Slavenburg Corp. v. Opus Apparel, Inc.
422 N.E.2d 570 (New York Court of Appeals, 1981)
Manshul Construction Corp. v. Board of Education
154 A.D.2d 38 (Appellate Division of the Supreme Court of New York, 1990)
Seven Acre Wood Street Associates, Inc. v. Town of Bedford
302 A.D.2d 511 (Appellate Division of the Supreme Court of New York, 2003)
Price v. New York City Board of Education
16 Misc. 3d 543 (New York Supreme Court, 2007)
In re Deeds
156 Misc. 2d 805 (New York Surrogate's Court, 1992)

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Bluebook (online)
25 Misc. 3d 339, Counsel Stack Legal Research, https://law.counselstack.com/opinion/zeichner-v-mamaroneck-union-free-school-district-nysupct-2009.